HASC FY25 NDAA Acquisition Marks

Streamline processes, buy commercial, and invest in emerging tech.

The House Armed Services Committee (HASC) released their draft FY25 NDAA.

The following are the Defense Tech and Acquisition sections of interest along with our analysis.

802: Streamlining Milestone B Requirements

This section would modify 10 USC 4252, to streamline the Milestone B approval process for major defense acquisition programs by focusing decisions on risks in each program and reducing redundant and unnecessary documentation burdens on program managers.

Our Take: We fully agree with streamlining the statutory requirements associated with MDAPs. SAEs and OSD can still require these documents where it makes sense for the program and tailor or waive them when conditions warrant.

As a reminder, these are the (ridiculous) certification requirements today:

• Certifies based on preliminary design reviews, that the program demonstrates a high likelihood of accomplishing its intended mission;

• Certifies that the technology has been demonstrated in a relevant environment with an independent review and technical risk assessment;

• Certifies that the program is affordable considering alternative systems;

• Certifies appropriate trade-offs among cost, schedule, technical feasibility, and performance objectives have been made to ensure affordability;

• Certifies that reasonable cost and schedule estimates have been developed to execute the product development and production plan under the program;

• Certifies the estimated procurement unit cost for the program and the estimated date for initial operational capability for the baseline description for the program do not exceed the program cost and fielding targets.

• Certifies that funding is expected to be available to execute the product development and production plan for the program;

• Certifies that appropriate market research has been conducted to reduce duplication of existing technology and products;

• Certifies that DoD has completed an analysis of alternatives;

• Certifies that the Joint Requirements Oversight Council has accomplished its duties including an analysis of the operational requirements for the program;

• Certifies that life-cycle sustainment planning has identified and evaluated relevant sustainment costs throughout development, production, operation, sustainment, and disposal of the program;

• Certifies that an estimate has been made of the requirements for core logistics capabilities and the associated sustaining workloads;

• Certifies there is a plan to mitigate and fund de-certification of cryptographic systems and components;

• Certifies the program complies with all DoD policies, regulations, and directives;

• Certifies the Secretary of the military department and the Chief of the armed force concurred in the cost, schedule and performance trade-offs;

• Certifies that modular open system approaches requirements were met;

• Certifies that appropriate actions have been taken to negotiate and enter into a contract for the technical data required to support the program;

• Certifies that the program has an approved life cycle sustainment plan with all the requisite reviews;

• Certifies that (for space programs) a cost benefit analysis has been conducted for any new or follow-on satellite system using a dedicated ground control system;

• Certifies that (for naval vessels) a Senior Technical Authority has been assigned.